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Medical Review Officer (MRO) – What You Need to Know

An MRO reviews laboratory drug test results to determine if there is a legitimate explanation for the presence of drugs in a person’s system (for example, prescription drugs taken under the supervision of a physician). Only after an MRO has reviewed a drug test result can the result be called positive for DOT and Federal workplace drug testing programs. The MRO also provides a quality assurance function by reviewing the paperwork for all drug test results.

Who can be an MRO?

An MRO must be a licensed physician who has been certified by an approved organization. Several organizations provide MRO training, but as of February 2013 only two organizations, the American Association of Medical Review Officers, and the Medical Review Officer Certification Council, are approved by the Health and Human Services (HHS) agency to certify MROs.

Is an MRO necessary for non-regulated drug testing?

Unless a particular state has a regulation requiring MROs to review drug test results, a company performing drug testing under their company’s policy can choose not to use an MRO. However, the use of MROs has become industry standard for defensible drug test results, so not using an MRO introduces an element of risk.

Why doesn’t an MRO review alcohol test results?

Several commenters responded to the original Notice of Proposed Rule Making in 1992 with the suggestion that an MRO review positive alcohol confirmation test results. In the preamble to the original DOT regulations published February 15, 1994, DOT gave this reasoning for why they would not require MRO review of alcohol test results:

The DOT rules prohibit safety sensitive employees from working with an alcohol level of 0.04. The source of the alcohol is irrelevant; it makes no difference whether the employee drank an alcoholic beverage or ingested medication to reach this intoxication level. Whether the alcohol source was medication or whiskey, both sources are legal (and the impairment of the individual would be the same). Therefore, there is nothing for an MRO to decide – there is no “legitimate explanation” that will excuse the presence of a 0.04 alcohol concentration.